Dark future for Canadian bundles Canada’s recent transfer pricing reforms have opened up the prospect of recharacterization of bundled transactions. Janice McCart of Bennett Jones and Emma Purdy of Ernst & Young in Toronto advise multinationals on how to avoid this worrying possibility
Ralph delivers at last Australia’s Ralph Committee has delivered its long-awaited report. Delight over tax cuts has been tempered by other measures. Rosie Murray-West reports
Linklaters advises on NatWest assurance takeover KPMG is advising National Westminster Bank (NatWest) on the £10.8 billion ($17.4 billion) takeover of life assurer Legal & General. NatWest's plunge into the pension and insurance market reflects a growing trend among British banks.
Masco turns to Davis Polk Michigan-based Masco Corporation has made a series of acquisitions within the home-improvement market.
Carrefour and Promodes in friendly merger Carrefour and Promodes have merged to form Europe's largest retailer. The Ffr111 billion ($17.7 billion) deal will produce a combined chain of 9000 stores, and anticipated net sales of Ffr355 billion ($56.5 billion) this year.
Viacom and CBS merge to rule the airwaves The US media company Viacom has bought the CBS Corporation for $35 billion, a record media deal.
Sun Life sells Guardian Royal Exchange businesses To Aegon UK Sun Life and Provincial Holdings has been consulting Slaughter and May over the disposal of its Guardian Royal Exchange UK life, pensions and trust businesses.
LTV adds to recent acquisitions LTV, America's third largest steelmaker, has bought the tubular steel manufacturers Copperweld Corporation and Copperweld Canada for $650 million.
Gibson Dunn & Crutcher advises on Hilton deal Hilton Hotels has announced a $4 billion takeover of the Promus Hotels Corporation.
Ashurst Morris Crisp in Henlys reverse takeover Henlys Group of the UK has announced the $665 million acquisition of the Blue Bird Corporation, the leading US school bus maker.
Andersens advises on Vickers deal Rolls Royce will pay £576 million ($939.6 million) in a cash deal for the British engineering group Vickers. They will acquire the Vickers-owned Norwegian company Ulstein, signalling Rolls' intention to move into the marine engineering industry.
Weil Gotshal advises on Eurocredit CDO Weil, Gotshal & Manges has been assisting Morgan Stanley on the introduction of Eurocredit, a Euro416.5 million ($436.3 million) collateralized debt obligation.
Ernst & Young advises on landmark Irish deal Edgemead, a company backed by the venture capital group Candover Partners, has placed a Euro385 million ($403 million) cash offer for Clondalkin group, an international producer of packaging and print materials.
Scottish & Newcastle buys Greenalls Scottish & Newcastle, the UK's largest brewer, has bought 50% of the Greenalls leisure group.
Rodewig swaps Daimler for Haarmann Heinrich Rodewig is joining the German firm Haarmann, Hemmelrath & Partner, having moved from Daimler-Benz. He will be working as tax partner in the international mergers and acquisitions group.
Ernst & Young expands Canadian litigation Donahue & Partner, the Canadian member firm of Ernst & Young International, has recruited tax litigators Al Meghji and Roger Taylor. The move reunites the two, who worked together at the Canadian department of justice for many years.
Bennett Jones faces E&Y exodus What's happening at Bennett Jones?The Calgary firm has decided to discontinue merger talks with Tory Tory Deslauriers & Binnington in Toronto. At the same time, the firm is losing tax partners to Ernst & Young
IRS calls for disclosure delay The IRS has asked the tax court for a delay in the planned disclosure of APAs. But the plaintiffs in the case have objected. Oliver Ralph reports
Economic boom prompts Swedish tax cuts The Swedish government is so confident in the growth of the economy that it has unveiled the first budget for a decade to include significant income and corporate tax cuts.
French government agrees to APAs The French administration recently finalized guidelines concerning the possibility of negotiating an Advance Pricing Arrangement (APA) in France.
Brazil increases tax burden The Brazilian internal revenue has drafted a bill forcing the introduction of a minimum corporate income tax. A further bill reducing company tax exemption to one year is also under consideration in the senate.
The UK puts brakes on withholding tax harmonization Britain has succeeded in temporarily blocking the EU's latest move towards tax harmonization.
Japanese help angels get off the ground The Japanese ministry of international trade and industry is to introduce tax reforms designed to encourage angel investment in Japan.
ECJ’s branch decision opens treaty networks The German government has lost a landmark case concerning the taxation of branches that will have an impact throughout the EU.
Turkish emergency taxes face tough passage The Turkish government's emergency tax initiative is facing a difficult passage through parliament.
Denmark disappoints with downbeat budget Danish businesses are up in arms following a draft budget that not only failed to announce a corporate tax cut, but also proposed a significant rise in environmental taxes.
Diary Bringing you the latest news on expected budgets, legislative changes and treaties from around the world
US eases foreign distribution The IRS’ active summer included final regulations on the treatment of distributions to foreign shareholders. This is good news for shareholders but taxpayers should beware the anti-abuse provisions. Mike Swanick and Aldrich Boss of PricewaterhouseCoopers in London report
Thai reforms tempt merger mania The Thai government has responded to the economic crisis by removing tax obstacles to encourage mergers. Paul Stitt and Doug Allan of PricewaterhouseCoopers in Bangkok examine the relative merits of amalgamations and asset transfers under the new regime
Can the big five play the legal game? The big five claim that they will soon be in a position to offer the complete tax service, from audit to litigation. But does the reality live up to the hype? Oliver Ralph looks behind the high profile recruitments and bar association debates and asks if tax directors expect one-stop-shopping in the near future
China pricing under the microscope The Chinese authorities have announced a crackdown on perceived transfer pricing abuses. Cassie Wong and Spencer Chong of PricewaterhouseCoopers in Hong Kong examine the new policy and advise multinationals on how to avoid a damaging audit
UK proposals miss the IP mark Recent UK proposals regarding withholding taxes on royalties have been largely overlooked but have wide ranging international implications. Malcolm Naylor, managing partner of Arthur Andersen’s UK tax and legal practice, explains
New Zealand irons out tax The New Zealand government has ironed out a number of kinks in the tax system. Changes have been made to the conduit tax rules and joint bank accounts, among other areas. Craig Elliffe and Nathan Banks of KPMG in Auckland look at the consequences for multinationals
Finance bill lightens the load in France France’s draft finance bill for 2000 includes changes to the participation exemption, merger rules, enterprise zones, registration duty and the business liscence tax. Michel Magnon and Dominique Bera of Deloitte & Touche in Paris explain the most important proposals.
US delights project financiers The doomed US tax cut bill has sparked a wide debate over the future direction of tax policy. One of it’s most striking features is the array of benefits offered to the project finance community. Keith Martin of Chadbourne & Parke in Washington explains what is at stake
Indian rulings spark treaty uncertainty A number of recent rulings in India have denied treaty relief to residents of low-tax jurisdictions. Frank D’Souza, Keyur Shah and Jatin Goradia of Arthur Andersen in Mumbai examine the consequences for other double tax agreements signed by India
